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Item 1 - Cover Page
FORM ADV PART 2A
Hammond Iles Wealth Advisors
100 Great Meadow Road, Suite 701
Wethersfield, CT 06109
P: 860-258-2600 or 800-416-1655
F: 860-258-2607
www.hiwealth.com
February 9, 2026
This brochure provides information about the qualifications and business practices of Hammond
Iles Wealth Advisors. If you have any questions about the contents of this Brochure, please
contact us at (860) 258-2600 or (800) 416-1655 and/or clientcare@hiwealth.com. The information
in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Kelly Financial Group, LLC dba Hammond Iles Wealth Advisors is
also available on the SEC's website at www.adviserinfo.sec.gov. The searchable IARD/CRD
number for Hammond Iles Wealth Advisors is 136372.
Any reference to Hammond Iles Wealth Advisors as a registered investment adviser or its related
persons as registered advisory representatives does not imply a certain level of skill or training.
Item 2 Material Changes
At least annually, this section will discuss only specific material changes that are made to the Brochure
and provide you with a summary of such changes. Additionally, reference to the date of the last annual
update to this Brochure will be provided.
Our last annual update of the brochure was March 12, 2025.
Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and
subsequent brochures within 120 days of the close of our fiscal year, which is December 31st. We may
further provide other ongoing disclosure information about material changes as necessary.
Additionally, we will further provide you with a new brochure as necessary based on change or new
information, at any time, without charge.
Our brochure can be requested free of charge by contacting Scott Solod at (860) 258-2600 or (800)
416-1655 and/or clientcare@hiwealth.com.
Additional information about Hammond Iles Wealth Advisors is also available via the SEC’s website
www.adviserinfo.sec.gov. The website also provides information about any persons affiliated with
Hammond Iles Wealth Advisors who are registered, or are required to be registered, as investment
adviser representatives of Hammond Iles Wealth Advisors.
Item 3 Table of Contents
Item 2 Material Changes .................................................................................................................................. 2
Item 3 Table Of Contents ................................................................................................................................. 3
Item 4 Advisory Business ................................................................................................................................. 4
Item 5 Fees and Compensation ...................................................................................................................... 8
Item 6 Performance-Based Fees and Side by Side Management ........................................................... 10
Item 7 Types of Clients ................................................................................................................................... 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 11
Item 9 Disciplinary Information ...................................................................................................................... 13
Item 10 Other Financial Industry Activities and Affiliations ........................................................................ 13
Item 11 Code of Ethics, Participation of Interest in Client Transactions and Personal Trading ........... 14
Item 12 Brokerage Practices ......................................................................................................................... 15
Item 13 Review of Accounts .......................................................................................................................... 18
Item 14 Client Referrals and Other Compensation ..................................................................................... 18
Item 15 Custody .............................................................................................................................................. 18
Item 16 Investment Discretion ....................................................................................................................... 19
Item 17 Voting Client Securities .................................................................................................................... 20
Item 18 Financial Information ........................................................................................................................ 20
Item 19 Requirements for State Registered Advisers ................................................................................ 20
Item 20 Additional Information ....................................................................................................................... 20
Item 4 Advisory Business
Hammond Iles Wealth Advisors ("HIWA") is a registered investment adviser firm established in 2001.
We provide personalized investment advisory services designed to meet the unique financial needs
and objectives of our clients.
HIWA is primarily owned and managed by R. Gregory Hammond, Managing Member. Scott Iles serves
as President and holds a secondary ownership interest. Detailed background information regarding
Mr. Hammond and Mr. Iles is available in the attached Supplemental Brochures.
HIWA offers the following investment advisory services:
• Diversified Portfolio Management Program (DPM): A discretionary asset management
service tailored to individual client needs.
• Financial Planning & Consulting Services: Comprehensive financial planning and consulting
covering various financial aspects.
• Educational Seminars/Speaking Engagements: Educational presentations on financial
topics.
Each of these services is described in greater detail below.
HIWA is committed to providing personalized investment advice. We gather comprehensive financial
information from each client to understand their unique circumstances. This information may include,
but is not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Risk tolerance
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by HIWA in order to provide the investment
advisory services requested.
This information allows HIWA to develop customized investment strategies and recommendations
appropriate for each client's financial situation. Clients may impose reasonable restrictions and
limitations on investments in specific securities or types of securities.
HIWA does not participate in any wrap fee programs.
As of December 31, 2025, HIWA manages $ 474,882,133 in client assets on a discretionary basis.
HIWA does not offer non-discretionary asset management services.
Diversified Portfolio Management Program (DPM)
HIWA's DPM service provides discretionary asset management based on a client's individual
investment goals, objectives, risk tolerance, and time horizon. The program's objective is long-term
growth that outpaces inflation, achieved through broadly diversified portfolios regularly reviewed and
rebalanced.
A. Investor Profile: HIWA conducts thorough consultations with clients to gather detailed financial
information and determine appropriate investment guidelines, risk tolerance, and suitability
factors.
B. Portfolio Management Selection: HIWA manages client portfolios with a focus on diversification.
Investment decisions are based on the client's investment objectives, risk tolerance, net worth,
income, and other relevant factors. Portfolios are managed on an individualized basis, and
client-imposed restrictions and guidelines affect portfolio composition and performance.
C. 55IP, LLC Services: HIWA may utilize the model portfolio services, tax transition, tax loss
harvesting, tax withdrawal services, and trade execution services provided by 55IP, LLC
("55IP"). These services are provided to HIWA at no direct cost. 55IP is compensated directly
by the product sponsors that comprise 55IP Model Portfolios. 55IP is the marketing name used
by 55 Institutional Partners, LLC, an investment technology developer, and for investment
advisory services provided by 55IP, LLC, an SEC-registered investment adviser. 55IP is part of
J.P. Morgan Asset Management, the brand for the asset management business of J.P. Morgan
Asset Management and its affiliates worldwide.
D. Performance Evaluation and Monitoring: Clients receive monthly or quarterly account reports
from the account custodian. HIWA develops customized asset allocations based on each
client's financial profile. Model portfolios serve as a starting point, but allocations are adjusted
to reflect individual client circumstances, market conditions, and any client-imposed restrictions.
HIWA provides continuous and ongoing portfolio management and, unless otherwise
requested, manages accounts on a discretionary basis, making changes as deemed
appropriate. HIWA may actively trade securities and may hold positions for short-term or long-
term periods. Clients grant discretionary authority to HIWA through the Client Agreement.
HIWA primarily utilizes exchange-traded funds (ETFs) and open-ended, no-load and load-waived
mutual funds purchased at net asset value (NAV). When deemed appropriate, HIWA may also utilize
closed-end funds and fixed income securities, including, but not limited to, Certificates of Deposit, U.S.
Treasury Securities, corporate and municipal bonds, and preferred stocks. Transactions and portfolio
rebalancing are generally taxable events, except within qualified retirement accounts.
Financial Planning & Consulting Services
Financial planning services are based on the client's current financial situation and information
provided to HIWA. Clients should be aware that certain assumptions are made regarding interest
rates, inflation, and market performance, and past performance is not indicative of future results. HIWA
cannot guarantee the achievement of financial goals. Clients are responsible for reviewing and
updating their financial plan as their circumstances, goals, or the economy change. Clients must
promptly notify HIWA of any changes. HIWA's advice may be limited in scope, and clients may need to
consult with other professionals, such as insurance advisors, attorneys, or accountants.
Clients are under no obligation to implement financial plan recommendations through HIWA. If a client
chooses to implement a plan through HIWA's representatives, they may receive commissions or other
compensation in addition to the advisory fee paid to HIWA.
Educational Seminars/Speaking Engagements
HIWA offers educational seminars and presentations on various financial topics. These events are
generally educational and informative and do not provide specific advice tailored to individual financial
situations. Individuals seeking personalized advice are encouraged to schedule a consultation with
HIWA.
General Information
Investment recommendations and advice provided by HIWA do not constitute legal or accounting
advice. Clients should consult with their attorney and/or accountant regarding the implications of
financial advice. Clients are responsible for promptly informing HIWA of any changes in their financial
situation, goals, or objectives. Failure to do so may result in investment recommendations that may no
longer meet your needs.
IRA Rollover Recommendations
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
IRA Rollover Considerations
As part of our consulting and advisory services, we offer recommendations and advice concerning your
employer retirement plan or other qualified retirement account. Our recommendations may include you
consider withdrawing the assets from your employer's retirement plan or other qualified retirement
account and rolling the assets over to an individual retirement account ("IRA"). Further, we offer our
management services to be applied to those funds and securities rolled into an IRA or other account
for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset-based fee as described below under Item 5. This practice
presents a conflict of interest because persons providing investment advice on your behalf have an
incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather
than solely based on your needs. You are under no obligation, contractually or otherwise, to complete
the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the
assets in an IRA managed by us.
It is important for you to understand that many employers permit former employees to keep their
retirement assets in their company plan. Also, current employees can sometimes move assets out of
their company plan before they retire or change jobs. In determining whether to complete the rollover
to an IRA, and to the extent the following options are available, you should consider the costs and
benefits of each.
An employee will typically have four options:
1. Leave the funds in your employer's (former employer's) plan.
2. Move the funds to a new employer's retirement plan.
3. Cash out and take a taxable distribution from the plan.
4. Roll the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your tax adviser.
If you are considering rolling over your retirement funds to an IRA for us to manage it is important you
understand the following:
• Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
o Employer retirement plans generally have a more limited investment menu than IRAs.
o Employer retirement plans often have unique investment options not available to the
public such as employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
o
If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
o You should understand the various products and services you might take advantage of
o
at an IRA provider and the potential costs of those products and services.
It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. In the event your plan
offers asset management or model management, there is a fee associated with the
services that is more or less than our asset management fee.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may offer financial advice, guidance, and/or model management or portfolio
•
options at no additional cost.
If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution.
• Your 401k may offer more liability protection than a rollover IRA; each state may vary.
• Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets
have been generally protected from creditors in bankruptcies. However, there can be some
exceptions to the general rules so you should consult an attorney if you are concerned about
protecting your retirement plan assets from creditors.
• You may be able to take out a loan on your 401k, but not from an IRA.
•
•
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
• Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important you understand the differences between these types of accounts and decide whether a
rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser
representative, or call our main number as listed on the cover page of this brochure.
Item 5 Fees and Compensation
Diversified Portfolio Management Program (DPM)
HIWA's DPM fees are negotiable and are based on several factors, including the complexity of the
client's situation, the size of the account, the assets being managed, and the scope of services
provided. Fees are not based on a share of capital gains or appreciation.
Clients may make additions to or withdrawals from their accounts, provided HIWA is notified. Fee
adjustments are not made for account deposits or partial withdrawals during a calendar quarter, nor
are they made for account appreciation or depreciation. HIWA may change the fee schedule with 30
days' prior written notice. For the benefit of discounting the account fee, HIWA will aggregate client
accounts from the same household. The maximum annual fee is 1%, however HIWA utilizes the
following fee schedule unless otherwise negotiated:
Tier 1
Tier 2
Tier 3
The First $1,000,000
The Next $3,000,000
$4,000,000
Over
0.99%
0.75%
0.50%
Initial advisory fees are payable upon receipt of HIWA's invoice or may be directly debited from the
client's account, provided HIWA has received written authorization. Account custodians will provide
statements reflecting fee deductions. If an account lacks sufficient funds to pay the advisory fee, HIWA
has limited authority to sell or redeem securities to cover the fee. Clients may reimburse the account
for advisory fees paid to HIWA, except for ERISA and IRA accounts.
In addition to HIWA's advisory fees, clients are responsible for the following expenses:
• Transaction Fees: Fees charged by the custodian for securities transactions. These fees vary
according to the custodian's fee schedule.
• Custodial Fees: Fees charged by the custodian for account maintenance and other services
(e.g., wire transfers, account closing fees, inactivity fees).
• Fund Expenses: For mutual funds, clients will bear their proportionate share of the fund's
management, administrative, and sales charges, including the mutual fund adviser's fee. These
fees are paid to the fund manager, not HIWA.
Some brokers offer no-transaction fee mutual funds. However, these funds may have holding period
requirements or short-term redemption fees, typically ranging from 30 to 90 days.
Advisory fees are charged quarterly in advance. The fee is calculated based on the portfolio value
(excluding individual stock positions) on the last business day of the preceding calendar quarter. The
initial fee is prorated based on the account value on the last business day of the quarter in which the
account was established.
Fee Calculation Example (for an $800,000 account):
Quarterly Advisory Fee = (Account Value x Annual Fee) / 365 days x Number of Days in the Quarter
Quarterly Advisory Fee = ($800,000 x 0.01) / 365 x 92 = $2,016 (approximately)
Fee Variations:
HIWA may, under certain circumstances, negotiate different fee arrangements with clients. These
circumstances may include the complexity of the account, anticipated future contributions, related
accounts, client retention, or pro bono activities. Any fee variations will be documented in the client's
advisory agreement.
Advisory Representatives of HIWA are dually Registered Representatives of Purshe Kaplan Sterling
Investments ("PKS"), a registered broker/dealer, member of the Financial Regulatory Authority
(FINRA) and SIPC. Securities such as some exchange traded funds, variable products, real estate
investment products, mutual funds, direct participation programs, and other registered investment
securities and pooled investment vehicles purchased through PKS on a commission basis will pay
trailing commission to registered individuals. Advisory Representatives of HIWA, who are Registered
Representatives, will receive trail commissions (i.e., 12b-1 fees) for a period of time as a result of
directing securities transactions through PKS. Load and no-load mutual funds pay annual distribution
charges, sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly
from your assets. 12b-1 fees are initially paid to PKS and a portion passed to the Advisory
Representatives in their role as Registered Representatives with PKS. The receipt of such fees
represents an incentive for the Advisory Representatives to recommend funds with 12b-1 fees over
funds that have no fees or lower fees. As a result, there is a conflict of interest. To mitigate this conflict
of interest this disclosure is provided.
HIWA recommends mutual funds that pay 12b-1 fees and no-load funds. You may purchase the
securities recommended by HIWA directly or through other brokers or agents not affiliated with HIWA.
12b-1 fees are not paid to Advisory Representatives for securities held in fee-based accounts.
Furthermore, registered investment securities such as mutual funds and variable products offer the
securities in various share classes. Different share classes are priced differently and share classes
other than institutional share classes will involve higher internal costs that over time will cost you more.
Institutional share classes often have higher trading costs. A client needs to consider the amount being
invested and the length of the anticipated holding period to make a decision as to the share class most
suitable to the client. Please read the disclosures under Item 10 below for important information about
the advice and recommendations offered by Advisory Representatives and Registered
Representatives.
HIWA will consider the lowest cost share class funds available and appropriate to the situation taking
into consideration several variables such as transaction fees, account activity such as systematic
investments and withdrawals, anticipated distribution needs, and investment time horizon. However, in
selecting the lowest cost share class, trading costs are sometimes higher. Selecting the lowest
cost share class appropriate to the situation does not imply the lowest cost share class but means
what HIWA deems lowest cost for the situation.
HIWA considers the anticipated holding period, cost structure, frequency of trading, and administrative
and transaction costs associated with selecting a share class. However, there is no way to predict the
future and there could be occasions where a holding is liquidated sooner or held longer resulting in
higher costs for the client. As a general guideline, HIWA will utilize non-transaction fee funds where the
client will pay higher internal costs for investments of less than $24,000. Advisory Representatives of
HIWA will not benefit from 12b-1 fees paid by the fund. No assurance can be provided that purchasing
institutional shares where trading costs are higher or no-transaction fee funds where internal costs are
higher as compared to institutional shares will be the least expensive because of the previous
mentioned variables. It is important for clients to understand all securities have costs and registered
investment securities, such as mutual funds and exchange traded funds, have internal costs and those
costs vary depending on the share classes purchased. The fund prospectus contains disclosure of
costs and fees.
Additional information about share classes can be found in an Investor Alert issued by the Securities
and Exchange Commission at https://www.investor.gov/introduction-investing/investing-
basics/glossary/mutual-fund-classes. Additionally, the SEC and FINRA provide investor information at
www.sec.gov and www.finra.org.
You may terminate investment advisory services obtained from HIWA, without penalty, upon written
notice within five (5) business days after entering into the advisory agreement with HIWA. You will be
responsible for any fees and charges incurred from third parties as a result of maintaining the account
such as transaction fees for any securities transactions executed and account maintenance or
custodial fees. Thereafter, you may terminate services upon HIWA's receipt of your written notice to
terminate. Should you terminate services during a quarter, you will be refunded a pro-rata portion of
the advisory fee for the quarter from the date of termination to the end of the calendar quarter.
Financial Planning & Consulting Services
Fees for financial planning services cover only the planning services themselves. Implementation of
recommendations, such as asset management or product purchases, will incur separate fees or
commissions.
Financial planning fees are negotiable and are quoted based on the scope and complexity of the
engagement. Fees may be charged on a flat fee basis (not to exceed $15,000) or an hourly basis (not
to exceed $300 per hour). A written quote will be provided outlining the estimated cost. Payment
schedules are negotiable and may be monthly, quarterly, or as agreed upon. Fees are due upon plan
engagement, however, HIWA does not require prepayment of advisory fees of more than $1,200 six
months or more in advance.
Clients may terminate their financial planning agreement within five business days of signing without
penalty. After that, termination requires written notice, and clients will be responsible for fees incurred
for time spent by HIWA.
Educational Seminars/Speaking Engagements
HIWA is compensated for its seminars or speaking engagements, depending on the engagement.
Fees will not exceed $150 per person. The fee for each workshop or seminar will be predetermined
and published on the seminar invitation. The fee will be based on several factors, including but not
limited to, content, length of the engagement, location, and number of attendees. Fees will generally
be due in advance and will only be refundable if the attendee cancels prior to the date of the workshop.
Fees will not be negotiable once determined.
Item 6 Performance-Based Fees and Side by Side Management
This section is not applicable to HIWA since HIWA does not charge performance-based fees.
Item 7 Types of Clients
HIWA provides investment advisory services to a diverse range of clients, including individuals (both
high-net-worth and other), corporations, and other business entities. While HIWA generally does not
impose a minimum account size requirement to open or maintain an advisory account, we reserve the
right to terminate accounts that, in our sole discretion, fall below a size that can be effectively
managed. This determination is based on various factors, including the client's investment objectives,
the complexity of their financial situation, and the cost-effectiveness of providing ongoing advisory
services. Prior to terminating an account for this reason, HIWA will provide written notice to the clients.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
HIWA constructs portfolios based on a long-term investment philosophy grounded in established
investment principles, including Modern Portfolio Theory (MPT), the Five-Factor Model, and the
Efficient Market Hypothesis (EMH). We believe markets are efficient over time, and that strategic asset
allocation, rather than market timing or individual stock selection, is the primary driver of long-term
investment success. This means we focus on determining the appropriate mix of asset classes (e.g.,
stocks, bonds, and cash) for each client based on their individual circumstances, risk tolerance, and
investment goals.
HIWA typically recommends broadly diversified portfolios using passively managed exchange-traded
funds (ETFs) and mutual funds. In certain situations, where it is appropriate to meet client objectives,
we may recommend direct investment in conservative fixed income securities. Passively managed
funds are generally designed to track a specific market index, offering broad diversification and
typically lower expense ratios compared to actively managed funds. Direct investment in conservative
fixed income securities may be used for clients seeking a more stable income stream or to manage
specific risk factors.
Our investment philosophy is designed for investors with a long-term, "buy and hold" orientation. We
emphasize a disciplined approach to asset allocation and periodic rebalancing to maintain the target
asset mix. While all investments carry risk, HIWA's approach seeks to manage risk through broad
diversification across asset classes and, for suitable clients, direct investment in conservative fixed
income securities. However, diversification does not guarantee a profit or protect against loss.
To implement investment plans, HIWA primarily utilizes ETFs and mutual funds, and, when
appropriate, portfolios of conservative fixed income securities. Clients may hold or retain other types of
assets (e.g., real estate, concentrated stock positions, alternative investments), and HIWA may provide
advice regarding these assets as part of its overall client service. While advice on these other assets
may not involve ongoing asset management, it can contribute to a client's broader financial well-being.
We will discuss the potential risks and benefits of holding such assets with each client.
We may utilize Defined Outcome ETFs as part of our investment strategies. These ETFs employ
options strategies to provide clients with defined downside protection and capped upside potential over
a specific period, aiming to potentially reduce or limit losses while also limiting gains. Defined Outcome
ETFs may be suitable for clients seeking downside protection against market volatility, predictable
return ranges, or specific investment outcome goals.
HIWA receives supporting research from J.P. Morgan Asset Management. This research may inform
our investment strategies and asset allocation recommendations. However, HIWA independently
determines the specific investments and portfolio construction for each client. While we utilize
investments that generally follow a passive asset class investment philosophy, we may adjust
portfolios based on market conditions, client needs, or other relevant factors including tax loss
harvesting.
55ip's services offered through the use of 55ip's proprietary technology incorporates a tax
management technique referred to as "tax loss harvesting" that is primarily used in the following ways:
"Tax-Smart Transitioning", "Ongoing Tax Management", and "Tax-Smart Withdrawals".
"Tax-Smart Transitioning" utilizes tax loss harvesting to offset realized gains and losses in order to
transition clients from legacy portfolio holdings to their target investment allocation strategy (including
Proxy Replacement Securities). This process seeks to make moving to different investment strategies
more tax-efficient. 55ip's approach seeks to capture investment losses in a client's portfolio which are
then used to offset near-term tax liabilities, help increase after-tax returns and minimize the tax liability
associated with moving to a different portfolio.
"Ongoing Tax Management" incorporates a recurring tax loss harvesting cycle which attempts to
create harvesting opportunities on a recurring basis, typically every 31 days. While 55ip seeks to
review accounts about every 31 days, there are circumstances when accounts are reviewed less
frequently. For tax loss harvesting, 55ip engages in trades intended to incur capital losses, typically by
selling a position within the target strategy and replacing it with a purchase of a Proxy Replacement
Security.
"Tax-Smart Withdrawal" generates withdrawal scenarios in order to help Clients determine if they
prefer to minimize taxes (but increase tracking error relative to the investment strategy) or minimize
impact to the account's tracking error relative to the investment strategy (but increase the tax liability).
Certain strategies engage in more active and frequent trading, leading to increased portfolio turnover.
Risk Disclosure:
All investments involve the risk of loss, including the potential loss of principal. Clients participating in
HIWA's management programs must be prepared to accept this risk and the possibility of fluctuating
performance. Market conditions, economic events, and other factors can significantly impact
investment returns.
HIWA does not represent, warrant, or imply that its services or methods of analysis can predict future
results, identify market tops or bottoms, or insulate clients from losses due to market corrections or
crashes. Past performance is not indicative of future results, and no guarantees can be made
regarding the achievement of investment goals or objectives. Furthermore, no assurance is given that
HIWA's advisory services will outperform other investment strategies. It is important for clients to
understand that investment returns can fluctuate significantly, and there is always the possibility of
losing money.
As stated above, HIWA primarily uses exchange-traded funds (ETFs) and mutual funds.
• Mutual Funds: Investing in mutual funds involves certain risks, including the impact of internal
fund expenses on performance, potential changes in fund management, and the possibility of a
fund deviating from its stated investment objective. While open-ended mutual funds typically
offer good liquidity, their net asset value (NAV) is calculated only once per day. Mutual fund
fees are detailed in the fund's prospectus, which is provided to clients by the account custodian
and is also available online through the fund company's website. HIWA will direct clients to the
appropriate website upon request.
• ETFs: ETFs trade on exchanges, resulting in greater price fluctuations compared to mutual
funds, as ETF prices can change throughout the trading day. Many ETFs track market indices,
limiting their potential to outperform the index, investors should not expect ETFs to exceed the
performance of the tracked index. Expenses associated with ETFs are detailed in the fund's
prospectus, which is provided to clients by the account custodian and is also available online
through the fund company's website. HIWA will direct clients to the appropriate website upon
request.
• Defined Outcome ETFs: It is crucial to understand that upside gains are capped, downside
protection is not absolute, and losses can still occur. These ETFs involve options strategies,
which carry inherent risks, and are subject to expense ratios which are higher than passive
ETFs. Defined outcome ETFs expenses are detailed in the fund's prospectus, which is provided
to clients by the account custodian and is also available online through the fund company's
website. HIWA will direct clients to the appropriate website upon request. The buffer and cap
levels of these ETFs define the potential return range, and clients should carefully consider
these factors before investing.
• ESG Investing: Upon client request, HIWA may incorporate Environmental, Social, and
Governance (ESG) factors into investment decisions. ESG investing, also known as
sustainable, socially responsible, or impact investing, considers environmental, social, and
governance issues alongside financial factors. ESG strategies may involve selecting companies
based on their ESG commitments or excluding companies in certain sectors or those deemed
to have poor ESG risk management.
o ESG Risk: ESG investing is subjective and lacks a standardized definition. There is no
universal ESG rating, and existing ratings can vary significantly. Different managers
may weigh ESG factors differently, and third-party data used in ESG assessments may
be subjective, unverified, or unreliable. A portfolio manager’s specific ESG practices can
significantly impact performance, potentially leading to performance that differs from the
broader market or comparable non-ESG accounts. ESG funds may also have higher
expense ratios.
Clients should understand that investment decisions involve inherent risks. HIWA's investment
strategies aim to mitigate these risks through diversification and careful security selection, but no
strategy can eliminate the possibility of loss. Clients should carefully consider their own risk tolerance
and financial circumstances before making any investment decisions.
Item 9 Disciplinary Information
Hammond Iles Wealth Advisors (HIWA) has no disciplinary history to report. Neither HIWA nor its
advisory representatives have been involved in any disciplinary events that would be required to be
disclosed in this section of Form ADV. This includes, but is not limited to:
• Criminal or regulatory actions
• Civil judicial proceedings
• Arbitration awards or settlements
• Disciplinary actions by self-regulatory organizations
Clients can access further information about HIWA and its representatives through the SEC's
Investment Adviser Public Disclosure (IAPD) website at https://adviserinfo.sec.gov.
Item 10 Other Financial Industry Activities and Affiliations
As previously stated, Advisory Representatives are dually registered as an Advisory Representative of
HIWA and as a Registered Representative of PKS. You are under no obligation to purchase or sell
securities through your Advisory Representative. However, if you choose to implement the plan,
commissions will be earned in addition to any fees paid for advisory services. Commissions are higher,
lower, or may be the same at PKS than at other broker/dealers. Advisory Representatives have a
conflict of interest in having you purchase securities and/or insurance related products through PKS in
that the higher their production with PKS the greater potential for obtaining a higher pay-out on
commissions earned.
Under the rules and regulations of FINRA, PKS has obligations to maintain records and perform other
functions regarding certain aspects of the investment advisory activities of its Registered
Representatives in relation to certain advisory accounts for which its Registered Representatives
provide advice. These obligations require PKS to coordinate with and have the cooperation of the
account custodian.
Neither HIWA nor management persons are registered or have an application pending as a futures
commission merchant, commodity pool operator, a commodity trading advisor, or an associated
person of the foregoing entities.
Kelly Financial Group, LLC is the legal name for the registered investment advisor doing business as
Hammond Iles Wealth Advisors and. Kelly Financial Group, LLC is also an insurance agency and
offers various insurance products for which Kelly Financial Group, LLC and Advisory Representatives
who are insurance licensed will receive commissions. Clients are under no obligation to purchase
insurance products through Kelly Financial Group, LLC or supervised persons. Clients are encouraged
to obtain quotes and comparisons from other insurance professionals. No guarantees are offered that
the insurance products and services are the lowest cost or the best quality. There are various products
available at various cost and quality levels. The receipt of commissions for the sale of insurance
products is a conflict of interest.
HIWA attempts to mitigate the conflicts of interest with the receipt of commissions if recommendations
are implemented by providing you with these disclosures. Further, you are encouraged to consult other
professionals and may implement recommendations through other financial professionals.
Furthermore, as Registered Representatives with PKS, Advisory Representatives are subject to a
supervisory structure at PKS for their securities business.
Item 11 Code of Ethics, Participation of Interest in Client Transactions and
Personal Trading
Code of Ethics
HIWA has a fiduciary duty to you to act in your best interest and always place your interests first and
foremost. HIWA takes seriously its compliance and regulatory obligations and requires all staff to
comply with such rules and regulations as well as HIWA's policies and procedures. Further, HIWA
strives to handle your non-public information in such a way to protect information from falling into
hands that have no business reason to know such information and provides you with HIWA's Privacy
Policy. As such, HIWA maintains a code of ethics for its Advisory Representatives, supervised persons
and staff. The Code of Ethics contains provisions for standards of business conduct to comply with
federal securities laws, personal securities reporting requirements, pre-approval procedures for certain
transactions, code violations reporting requirements, and safeguarding of material non-public
information about your transactions. Further, HIWA's Code of Ethics establishes HIWA's expectation
for business conduct. A copy of our Code of Ethics will be provided to you upon request.
HIWA and its associated persons buy or sell securities identical to those securities recommended to
you. Therefore, HIWA and/or its associated persons could have an interest or position in certain
securities that are also recommended and bought or sold to you. HIWA and its associated persons will
not put their interests before your interest. HIWA and its associated persons cannot trade in such a
way to obtain a better price for themselves than for you or other clients.
HIWA is required to maintain a list of all securities holdings for its associated persons and develop
procedures to supervise the trading activities of associated persons who have knowledge of your
transactions and their related family accounts at least quarterly. Further, associated persons are
prohibited from trading on non-public information or sharing such information.
Prohibition on Use of Insider Information
HIWA has adopted policies and procedures to prevent the misuse of "insider" information (i.e.,
material, non-public information). A copy of such policies and procedures is available to any person
upon request.
Item 12 Brokerage Practices
As previously stated, Advisory Representatives are Registered Representatives of PKS. As a result,
they are subject to FINRA Conduct Rule 3040 which restricts them from conducting securities
transactions away from PKS unless PKS provides them with written authorization. HIWA is
independently owned and operated and not affiliated with PKS.
Not all investment advisers require you to maintain accounts at a specific broker/dealer. You may
maintain accounts at another broker/dealer. However, the services provided by HIWA could be limited
to only advice and may not include implementation, if PKS does not grant Advisory Representatives
authorization to execute transactions.
HIWA does not maintain physical custody of your assets that we manage, although we are deemed to
have custody under two situations. First, we are deemed to have custody if you give us authority to
withdraw our fees from your account (see Item 15 Custody, below). Your assets must be maintained in
an account at a "qualified custodian," generally a broker-dealer or bank. We are independently owned
and operated and not affiliated with Schwab. Second, we are deemed to have custody if you have a
third-party standing authorization and we have the authority to change the amount or timing of the
transfers upon your request.
HIWA has an arrangement with Charles Schwab & Co., Inc ("Schwab"), a FINRA registered broker-
dealer, member SIPC, as a qualified custodian. Schwab will hold your assets in a brokerage account
and buy and sell securities when we instruct them to. While we request that you use Schwab as
custodian/broker, you will decide whether to do so and open your account with Schwab by entering
into an account agreement directly with Schwab. Even though your account is maintained at Schwab,
we can still use other brokers to execute trades for your account, as described in the next paragraph.
How We Select Brokers/Custodians
We seek to select a custodian/broker who will hold your assets and execute transactions on terms that
are overall most advantageous when compared to other available providers and their services. Best
execution does not simply mean the lowest transaction cost. Therefore, no single criteria will validate
nor invalidate a custodian, but rather, all criteria taken together will be used in evaluating the currently
utilized custodian. We consider a wide range of factors, including, among others, these:
• Ability to service you and us
• Combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear and settle trades (buy and sell securities for your account)
• Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
• Industry reputation, staying power as a company, financial strength and viability
• Technology and educational resources
• Confidentiality and security of your information
There is an incentive for HIWA and the Advisory Representatives to recommend a broker/dealer over
another based on the products and services that will be received rather than your best interest.
Charles Schwab & Co., Inc. ("Schwab")
Your Custody and Brokerage Costs
For our clients' accounts it maintains, Schwab generally does not charge you separately for custody
services but is compensated by charging you commissions or other fees on trades that it executes or
that settle into your Schwab account. Schwab is also compensated by earning interest on
the uninvested cash in your account in Schwab's Cash Features Program. In addition to commissions,
Schwab charges you a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we
have executed by a different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your Schwab account. These fees are in addition to the
commissions or other compensation you pay the executing broker-dealer. Because of this, in order to
minimize your trading costs, we have Schwab execute most trades for your account.
Products and Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab's business serving
independent investment advisory firms like us. They provide us and our clients with access to its
institutional brokerage - trading, custody, reporting and related services - many of which are not
typically available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients' accounts while others help us
manage and grow our business. Schwab's support services are generally available on an unsolicited
basis (we don't have to request them) and at no charge to us as long as we keep a total of at least $10
million of our clients' assets in accounts at Schwab. If we have less than $10 million in client assets at
Schwab, it may charge us quarterly service fees. The following is a more detailed description of
Schwab's support services:
Services that Benefit You. Schwab's institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of client assets. The
investment products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients. Schwab's
services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You. Schwab also makes available to us other products and
services that benefit us but may not directly benefit you or your account. These products and services
assist us in managing and administering our clients' accounts. They include investment research, both
Schwab's own and that of third parties. We may use this research to service all or some substantial
number of our clients' accounts, including accounts not maintained at Schwab. In addition to
investment research, Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
statements);
• facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide pricing and other market data;
• facilitate payment of our fees from our clients' accounts; and
• assist with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Us. Schwab also offers other services intended to help us
manage and further develop our business enterprise. These services include:
• educational conferences and events
• technology, compliance, legal, and business consulting;
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party's fees. Schwab may also provide us with other benefits such as
occasional business entertainment of our personnel.
Our Interest in Schwab's Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don't have to pay for Schwab's services so long as we keep a total of at least $10
million of client assets in accounts at Schwab unless Schwab otherwise decides to waive the fee.
Beyond that, these services are not contingent upon us committing any specific amount of business to
Schwab in trading commissions or assets in custody. The $10 million minimum gives us an incentive to
recommend that you maintain your account with Schwab based on our interest in receiving Schwab's
services that benefit our business rather than based on your interest in receiving the best value in
custody services and the most favorable execution of your transactions. This is a conflict of interest.
We believe, however, that our selection of Schwab as custodian and broker is in the best interests of
our clients. It is primarily supported by the scope, quality and price of Schwab's services (based on the
factors discussed above - see "How We Select Brokers/Custodians") and not Schwab's services that
benefit only us.
Purshe Kaplan Sterling Investments ("PKS")
PKS has a wide range of approved securities products for which PKS performs due diligence prior to
selection. PKS' Registered Representatives are required to adhere to these products when
implementing securities transactions through PKS. Commissions charged for these products are
higher, lower, or may be the same as the commissions you could obtain if transactions were
implemented through another broker/dealer. PKS also provides Advisory Representatives, and
therefore HIWA, with back-office operational, technology, and other administrative support. Other
services may include consulting, publications and conferences on practice management, information
technology, business succession, regulatory compliance and marketing. Such services are intended to
help Advisory Representatives and HIWA manage and further develop its business enterprise.
PKS and its clearing broker/dealer also make available to HIWA other products and services that
benefit HIWA but may not directly benefit you. Some of these other products and services assist HIWA
with managing and administering your accounts. These include software and other technology that
provide access to your account data (such as trade confirmation and account statements); facilitate
trade execution; provide research, pricing information and other market data; facilitate payment of
HIWA's fees from your accounts; and assist with back-office functions; record-keeping and client
reporting. Many of these services generally may be used to service all or a substantial number of
HIWA's accounts, including accounts not held through PKS.
Aggregated Trading
HIWA can aggregate ("bunch") transactions in the same security on behalf of more than one client in
an effort to strive for best execution and to possibly reduce the price per share and/or other costs to
clients. However, aggregated or bunched orders will not reduce the transaction costs to participating
clients. HIWA conducts aggregated transactions in a manner designed to ensure that no participating
client is favored over another client. Participating clients will obtain the average share price per share
for the security executed that day. To the extent the aggregated order is not filled in its entirety and
when possible, securities purchased or sold in an aggregated transaction will be allocated on a random
basis. Under certain circumstances, the amount of securities may be increased or decreased to avoid
holding odd-lot or a small number of shares for particular clients.
Item 13 Review of Accounts
If you are participating in the Diversified Portfolio Management Program you will be invited to
participate in reviews at least annually or as agreed by you and your Advisory Representative. You
may request more frequent reviews. The review process encompasses the following:
• Goal Assessment: Revisiting and assessing the client's current financial goals and objectives.
• Strategy Evaluation: Evaluating the performance and suitability of the investment strategy
employed.
• Portfolio Monitoring: Ongoing monitoring of the portfolio, conducted at least quarterly, to
ensure alignment with the client's investment objectives and risk tolerance.
• Rebalancing: Addressing the need for portfolio rebalancing based on market conditions,
changes in the client's circumstances, or deviations from the target asset allocation.
HIWA's Advisory Representatives continuously monitor relevant factors, including economic shifts,
changes in the management or structure of mutual funds or companies held in client portfolios, and
market trends and corrections.
Clients utilizing Financial Planning & Consulting Services do not receive regularly scheduled reviews
from HIWA. However, HIWA strongly recommends that clients conduct an annual review and update of
their financial plan. The frequency and timing of these reviews are determined solely by the client.
Additional reviews are subject to the fees outlined in the Financial Planning & Consulting Services
section of Item 5.
Clients are responsible for promptly notifying their Advisory Representative of any changes to their
financial goals, objectives, or financial situation. Such changes may necessitate a review of the
portfolio allocation and corresponding recommendations from the Advisory Representative.
Clients will receive account statements directly from the account custodian at least quarterly.
Transaction confirmations will also be provided directly by the account custodian for all account
activity.
Item 14 Client Referrals and Other Compensation
HIWA receives certain economic benefits from Schwab in the form of support products and services
made available to independent investment advisers whose clients maintain accounts at Schwab.
These benefits are described in detail in Item 12 – Brokerage Practices.
These arrangements create a potential conflict of interest, as HIWA's receipt of these benefits could
incentivize us to recommend or maintain client accounts at Schwab, regardless of whether it is in the
client's best interest. However, the availability of these products and services is not contingent upon
HIWA recommending specific securities or providing particular investment advice to clients. Our
recommendations are based solely on our assessment of the client's needs and objectives.
HIWA may receive support from product vendors, including monetary and non-monetary assistance
related to client events, educational tools and resources. Additionally, product sponsors, insurance
companies, and third-party managers may occasionally cover the costs of due diligence meetings,
educational conferences, and/or travel expenses for HIWA representatives.
While HIWA values these resources, our product selection process is independent and driven by due
diligence. The receipt of any monetary or non-monetary assistance does not influence our product
selection decisions. HIWA's due diligence process does not consider any potential assistance that
might be received. Our primary focus is on identifying products that are suitable and appropriate for our
clients' individual needs.
HIWA does not compensate non-advisory personnel (solicitors/promoters) for client referrals.
Item 15 Custody
Schwab will directly debit client accounts for the payment of HIWA's advisory fees. This authorization
grants HIWA limited custody over client funds and securities solely for the purpose of fee collection.
HIWA does not have physical custody of any client funds or securities. Client assets are held by
Schwab, a qualified custodian. Clients receive account statements directly from Schwab at least
quarterly, detailing all transactions, including advisory fee deductions. Clients should carefully review
these statements for accuracy.
Wire Transfer and/or Standing Letter of Authorization
HIWA or its representatives may execute wire transfers from client accounts to designated third
parties, as authorized in writing by the client via a Standing Letter of Authorization (SLOA). This
authorization permits HIWA to direct transfers to specified third parties on a pre-determined schedule
or on an ad-hoc basis, without requiring separate written consent for each individual transaction.
While SLOAs grant HIWA access to client assets for the purpose of facilitating these transfers, thereby
technically constituting custody, HIWA adheres to specific safeguards to ensure client protection and
comply with regulatory requirements. These safeguards exempt HIWA from the annual surprise
examination requirement typically applicable to advisers with custody:
1. Written Client Instruction: Clients provide written, signed instructions to Schwab, the qualified
custodian, specifying the third party's name, address, or account number.
2. Written Authorization to HIWA: Clients provide written authorization to HIWA, permitting the
firm to direct transfers to the designated third party on a specified schedule or as needed.
3. Custodian Verification and Notification: Schwab verifies the client's authorization and
promptly provides the client with a transfer of funds notice after each transfer.
4. Client Control: Clients retain the right to terminate or modify the SLOA at any time.
5. HIWA Limitations: HIWA has no authority to designate or change the identity of the third party,
their address, or any other information pertaining to the third party.
6. Record Keeping: HIWA maintains records demonstrating that the third party is not a related
party and is not located at the same address as HIWA.
7. Custodian Notices: Schwab sends an initial notice to the client confirming the SLOA and
provides an annual notice re-confirming the standing instruction.
By adhering to these conditions, HIWA complies with the "safe harbor" provisions related to custody
and is therefore exempt from the surprise audit requirement.
Item 16 Investment Discretion
By execution of HIWA's advisory agreement you grant HIWA authorization to manage your account on
a discretionary basis. Discretionary authority will give HIWA the authority to buy, sell, exchange,
convert securities in your managed accounts. You will grant such authority to HIWA by execution of the
advisory agreement. You can terminate discretionary authorization at any time upon receipt of written
notice by HIWA.
Additionally, you are advised that:
• You may set parameters with respect to when account(s) should be rebalanced and set trading
restrictions or limitations;
• Your written consent is required to establish any mutual fund, variable annuity, or brokerage
account;
• HIWA requires the use of the broker/dealer with which your Advisory Representative is
registered for sales in commissionable mutual funds or variable annuities if you elect to
implement recommendations through your Advisory Representative.
Item 17 Voting Client Securities
HIWA does not have discretionary authority to vote client securities. You will receive proxy materials
directly from the account custodian or transfer agent. We encourage you to contact us if you have
questions about proxy matters or would like our perspective on specific proposals. We are available to
discuss the potential impacts of different voting choices and provide general information. However, all
voting decisions are your responsibility. We do not provide specific voting recommendations.
Item 18 Financial Information
Hammond Iles Wealth Advisors (HIWA) has custody of client assets solely due to the use of Standing
Letters of Authorization (SLOAs). These authorizations are used exclusively to facilitate client-directed
transfers of funds to designated third parties. HIWA does not hold client assets directly.
HIWA adheres to all conditions of the Securities and Exchange Commission's (SEC) safe harbor rule
governing the use of SLOAs. This compliance exempts HIWA from the surprise examination
requirement typically applicable to investment advisers with custody.
Furthermore, HIWA does not require prepayment of advisory fees of more than $1,200 six months or
more in advance.
Item 19 Requirements for State Registered Advisers
Hammond Iles Wealth Advisors (HIWA) is registered with the Securities and Exchange Commission
(SEC) and is not a state-registered investment adviser. Therefore, this section, which pertains to
disclosures required of state-registered advisers, is not applicable to HIWA.
Item 20 Additional Information
Trade Errors: Hammond Iles Wealth Advisors (HIWA) is committed to rectifying any trade errors that
may occur in client accounts. Our policy is to restore client accounts to the position they would have
occupied if the error had not occurred. Depending on the specific circumstances of the error, corrective
actions may include, but are not limited to:
• Canceling the erroneous trade.
• Adjusting the portfolio allocation to reflect the intended investment strategy.
• Reimbursing the client account for any losses directly resulting from the error.
HIWA maintains records of all trade errors and the corrective actions taken. Clients will be notified
promptly of any trade errors affecting their accounts and the measures taken to rectify them.
Class Action Lawsuits: HIWA does not monitor client holdings to determine whether they are subject to
class action lawsuits or eligible to participate in class action settlements or litigation. Furthermore,
HIWA does not initiate or participate in litigation on behalf of clients to recover damages resulting from
actions, misconduct, or negligence by issuers of securities held in client portfolios. Clients are
responsible for monitoring their own investments for class action lawsuit eligibility and for pursuing any
related claims. HIWA recommends that clients consult with legal counsel or utilize available resources
to stay informed about potential class action opportunities.